{"operation":"document","citation":"PI-75-033","title":"Tennessee Public Service Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1975-07-02","effective_on":null,"summary":"PI-75-033 response to Tennessee Public Service Commission concerning 192.455.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-033.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-033.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-033","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1975/PI75033.pdf","body":"<<<PAGE 1>>>\n\nJuly 2, 1975\nMr. John Searcy\nEngineering Division\nTennessee Public Service Commission\nCordell Hull Building\nNashville, Tennessee 37219\nDear Mr. Searcy:\nThis refers to your letter of June 19, 1975, transmitting a letter petition for waiver from\ncompliance with 49 CFR 192.455(a) by the Memphis Light, Gas and Water Division as to\nfacilities apparently within the Commission's jurisdiction.\nBecause of the unique Federal and State relationship under the Natural Gas Pipeline Safety Act of\n1968, a petition for waiver regarding intrastate gas pipeline facilities under the jurisdiction of a\nState agency that has in effect a certification under §5(a) of the Act is properly submitted to that\nState agency. While §3(c) of the Act provides that the Secretary of Transportation finally\ndetermines whether the requested waiver may be granted, the Act is clear that the State agency,\nand not the Secretary, decides initially whether to grant or deny the waiver request.\nThus, the letter of petition is returned herewith.\nSincerely,\n\\signed\\\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\nEnclosure\ndal\\192\\455\\75-07-02\n1\n\n<<<PAGE 2>>>\n\nTENNESSEE PUBLIC SERVICE COMMISSION\nJune 19, 1975\nMr. Joseph Caldwell\nDepartment of Transportation\nOffice of Pipeline Safety\n2100 Second Street, SW\nWashington, D.C. 20590\nDear Mr. Caldwell:\nThe sentence in Section 3(e) of Public Law 90-481 reading \"A State agency...may waive\ncompliance...\" (emphasis this writer's) is permissive rather than mandatory, and we elect to have\nyou determine waiver requests. Accordingly, we submit the enclosed waiver request from\nMemphis Light, Gas and Water Division.\nSincerely,\n\\signed\\\nJohn Searcy, Engineer\nEngineering Division\nEnclosure\ndal\\192\\455\\75-07-02\n2\n\n<<<PAGE 3>>>\n\nMEMPHIS LIGHT, GAS AND WATER DIVISION\nJune 17, 1975\nTennessee Public Service Commission\nCordell Hull Building\nNashville, TN 37219\nGentlemen:\nSection 3(e) of the Natural Gas Pipeline Safety Act of 1968 authorizes any state agency certified\nunder Section 5(a) to waive compliance with any standard if the agency determines that the\nwaiver is not inconsistent with gas pipeline safety. The Memphis Light, Gas and Water Division\nhereby requests a deviation from the requirements of Part 192.455(a) of Subpart I to permit\ncomponents of pipeline fittings constructed of type 316 stainless steel to be installed without\ncoating and/or cathodic protection.\nMemphis Light, Gas and Water Division proposes to use type 316 stainless steel components for\nthe applications listed below:\n(a) Components of primarily plastic fittings used for transition of plastic to plastic in\ndirect burial applications.\n(b) Components of fittings used for transition from plastic to copper inside a conduit\nused as a service riser (see attached copy of MLGW's Construction Standard\n245.72).\ndal\\192\\455\\75-07-02\n3\n\n<<<PAGE 4>>>\n\n(c) Components of plastic fittings used for service tapping tees (see attached copy of\nMLGW's construction Standard 245.51).\nWe believe that a precedent was set when Southern California Gas Company was granted a\nwaiver in October, 1973. We are confident that the use of fittings with type 316 stainless\ncomponents without coating or cathodic protection is not inconsistent with pipeline safety. It is\nnot economically feasible to coat and cathodically protect the fitting components identified above\nand it would be an economic hardship to use carbon steel components with coating and cathodic\nprotection, and thereafter perpetually monitor the large number required each year. Therefore,\nthe\nMemphis Light, Gas and Water Division respectfully requests this deviation from Part 192.455(a)\nof Subpart I of the OPS Requirements for Corrosion Control.\nVery truly yours,\n\\signed\\\nIra C. Stanfill\nDirector, Gas Division\nEnclosures\ndal\\192\\455\\75-07-02\n4","truncated":false,"body_characters":3809}